The Claimant

1.The Claimant, Mr David John Cawdell Irving ("Irving") seeks permission to appeal against two orders of Gray J, the first dated 11th April 2000, and the second dated 5th May 2000.

2.By his order of 11th April 2000, Gray J ordered inter alia that judgment should be for the Defendants, Penguin Books Limited, ("Penguin") and Professor Deborah Lipstadt ("Lipstadt"), that the Claimant should be refused permission to appeal, and that the Claimant should pay the costs of the First and Second Defendants, to be the subject of a detailed assessment.

3.By his order of 5th May 2000, Gray J ordered inter aliathat, by four o'clock on Friday 16th June, 2000, the Claimant should pay the sum of £150,000 on account of costs to the First and Second Defendants, pending the detailed assessment directed by his order of 11th April 2000.

4.References in this skeleton argument to paragraphs by number are to the paragraphs so numbered in Gray J's judgment, save where otherwise stated.